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Home My WebLink About03-4365DEBERA JOAN SLOPEY, Plaintiff THEODORE RAY SLOPEY, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 0-~~ : : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divome is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list ofmamage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Attorney for Plaintiff DEBERA JOAN SLOPEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; v. : NO. : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE Plaintiffis Debera Joan Slopey, who currently resides at 7 Wineberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Defendant is Theodore Ray Slopey, Jr., who presently resides at 7 Wineberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on June 23, 1973, in Lycoming County, Pennsylvania. There have been no prior actions for divome or annulment between the parties. The Plaintiff is a citizen of the United States of America. The Defendant is a member of the Armed Services of the United States of America, namely the Pennsylvania Air National Guard but is currently not on active duty. Plaintiff avers that there are two children of the parties over the age o£ eighteen. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. THEODORE RAY SLOPEY, JR., Defendant 5. 6. 7. 10. 11. 12. 13. 14. 15. 16. 17. COUNT 1 REOUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c} OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. The marriage of the parties is irretrievably broken. COUNT II EOUITABLE DISTRIBUTION OF PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference thereto. The parties have acquired certain property and assets which constitute mahtal property. In the event the parties are unable to resolve distribution of marital property by way of an agreement, then this Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. COUNT III ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference thereto. Plaintiff is unable to sustain herself during the course of litigation and to prosecute this divorce action. Plaintiff lacks sufficient income and property to provide for her reasonable needs and is unable through appropriate employment. 18. 19. COUNT IV ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference thereto. Plaintiff is unable to pay her counsel fees, costs and expenses and Defendant, Theodore Ray Slopey, Jr., is full well and able to pay them. WHEREFORE, Plaintiffrequests this Honorable Court to: enter a decree dissolving the marriage between Plaintiff and Defendant; equitably distributing all marital property pursuant to §3502 of the Divorce a) b) Code. c) awarding Plaintiff alimony pendente lite tmtil final heating and thereupon to enter an order of alimony in her favor pursuant to §3701 and §3702 of the Divome Code and ordering Defendant, Theodore Ray Slopey, Jr., to pay the reasonable counsel fees, costs and expenses of Plaintiff. Respectfully Submitted, Supreme Court ID# 86889 Attorney for Plaintiff 101 South Market Street Mechanicsburg, Pennsylvania 17055 (717) 790-5451 VERIFICATION I verify that the statements made in the attached complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date; DEBERA JOAN SLOPEY, Plaintiff THEODORE RAY SLOPEY, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-04365 Civil Term : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Christopher J. Keller, Esquire, hereby certify that I have served the Defendant, THEODORE RAY SLOPEY, JR., with a copy of the divorce complaint on Septemberl3, 2003, by certified mail number 7003 1010 000 8131 2603 as evidenced by the attached original United States mail return receipt. I verify that the statements made in this Affidavit :are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Christophe~ J. Keller, Esquire Supreme Court ID# 86889 Attorney for Plaintiff 101 South Market Street Mechanicsburg, Pe~msylvania 17055 (717) 790-5451 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to; D. Is delivery address different from item 1 ? [] Yes If YES, enter delivery ad0ress below: [] No )t for Merchandise [] C.O.D. ~livery? (Ex~ Fee) 2. Article Number (rransferfromser¥icelabel) 7003 1010 0000 8131 2603 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540 UNITED STATES POSTAL SERVICE · Sender: Please print your name, address, and ZIP+4 in this box ® Law Office of Christopher J. Keller 101 South Market Street Mechanicsburg, PA 17055